Uniform Trade Secrets Internationally
Due to the size, scale, nuance, and complexity of international law and trade agreements, uniformity among trade secret acts is understandably not nearly as uniform as it is among U.S. states. The following are international examples of attempts at harmonizing trade secret code.
The North American Free Trade Agreement (NAFTA) has provisions providing for uniform minimum standards for protecting trade secrets.
Each party shall provide the legal means for any person to prevent trade secrets from being disclosed to, acquire by, or used by others without the consent of the person lawfully in control of the information in a manner contrary to honest commercial practices, in so far as:
— NAFTA Article 1711(1)
Trade Secrets in Europe are dealt with on a Country by Country basis. In the United Kingdom, specifically England, trade secret protection is predicated upon the common law concept of "breach of confidence." Meaning that, regardless of the existence of a contract, individual(s) who obtain the trade secret in confidence shall not take unfair advantage of it without consent.
Germany's Act against Unfair Competition states, "...any person who, in the course of business activity for purposes of competition, commits acts contrary to honest practices" and hold violators responsible for damages.
Read more about this topic: Uniform Trade Secrets Act
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